> What did you mean when you asked Mr. Maritz whether or not, "We have a clear plan on what we want Apple to do to undermine Sun"?
The Fifth Amendment doesn't help you here (for those of you who think it might). You can only use that to avoid incriminating yourself criminally and, then, it does not simply permit you to give whatever answer you want. When you invoke the Fifth you have to refuse to answer the question, you can't just lie.
And while perjury may be a stretch in most cases, there is also the matter of the jury's opinion of you as a witness (assuming that the case eventually goes to trial and you get confronted with your own deposition transcripts). If they think your memory seems a tad selective, then they're apt to assume that any fact you've "forgotten" is the worst possible fact for you. There are also concerns like civil/criminal contempt and other sanctions against your side in the litigation.
There is also the small matter of morality. Many of us think that you shouldn't lie in a deposition even if you can get away with it.
Depositions are sworn testimony. Even if you'd prefer not to answer the question, you have sworn to be truthful. Responding "I don't remember" to a question just because you'd prefer not to answer would violate your oath.